PROPORTIONALITY TEST - POLITY

News: Electoral Bonds verdict: How the proportionality test was applied in the case

 

What's in the news?

       Underlining that the restrictions on free speech by the electoral bonds scheme are not “proportional” to its goal, a five-judge Constitution Bench of the Supreme Court, headed by Chief Justice of India (CJI) DY Chandrachud, unanimously struck down the scheme.

 

Key takeaways:

       Essentially, the judicial review of the electoral bonds scheme involved examining whether the extent of the state’s encroachment into the rights of individuals was proportional to achieve its objectives — curbing black money and protecting donor privacy.

 

Doctrine of Proportionality:

       Proportionality is a ground for judicial review.

       In India, the doctrine of proportionality was adopted by the Supreme Court of India in the case of Om Kumar v. Union of India.

 

Definition:

       Proportionality means that the administrative action should not be more drastic than it ought to be for obtaining the desired result.

 

Constitutional Basis:

       In India, the doctrine is anchored in Article 14 of the Constitution, emphasizing equality before the law and the prevention of arbitrary state action.

       The Supreme Court has applied this principle to scrutinize the reasonableness and non-arbitrariness of administrative actions, ensuring they have a reasonable nexus with their objectives.

 

Features:

In K.S. Puttaswamy vs Union of India (2017) case, the court held that any restriction placed on the right must conform to a doctrine of proportionality. This requires few tests such as

       State action must have a legislative mandate.

       The action must show that the objective of its law is founded on a legitimate governmental aim.

       It must be proportionate, i.e., such state action — both in its nature and extent, must be necessary for a democratic society.

       Further, such action must have no alternative and less intrusive measures available to achieve the same objective

 

Significance:

       The principle of proportionality calls for striking down laws that are excessively harsh or disproportionate.

 

Proportionality and the Electoral Bond Scheme:

       While the direct impact of the doctrine on the Electoral Bond Scheme’s judicial review is not detailed in the provided sources, the principle typically requires examining whether a government scheme’s objectives justify its impacts on fundamental freedoms and transparency.

       In such a context, the doctrine would guide the assessment of whether the scheme’s aims, such as cleaner political funding, were achieved through the least restrictive means and without unduly infringing on democratic principles.